Roger and Sharon Wortmann, et al. - Page 24

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          expert’s conclusions as to the value of the property as of the              
          contribution date.                                                          
               D.  Assessed Value of Subject Property                                 
               We now address the assessed value of the subject property.             
          The assessed valuation of property is also evidence of the                  
          property’s value where, as is the case in Nebraska, the assessed            
          value is defined as the property’s fair market value.  See N.               
          Trust Co. v. Commissioner, 87 T.C. 349, 382 (1986); Neb. Rev.               
          Stat. sec. 77-112 (1996 & Supp. 2000).  Assessed valuation may be           
          used to corroborate fair market value determined under the three            
          traditional approaches.  See N. Trust Co. v. Commissioner, supra.           
               Here, the Antelope County assessor determined that the                 
          assessed value of the subject property for 1998 was $70,424.  The           
          assessment took into account physical depreciation, economic                
          obsolescence, and functional obsolescence in valuing the                    
          property.                                                                   
               We place great weight on the assessed value of the subject             
          property because it corroborates the actual sale and the                    
          valuation of respondent’s expert as indicators of the fair market           
          value of the subject property.  This unrelated third party                  
          valuation, close to the values in the prior sale and determined             
          by respondent’s expert, reinforces our view that the purchase               
          price of the property is persuasive evidence of its true fair               
          market value.13                                                             

               13Petitioners contend that the value the Antelope County               
          assessor determined is somehow biased and the assessor was simply           
                                                             (continued...)           




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